In short
Registration under the National Credit Act follows the act of granting credit. If you extend credit to consumers at arm’s length as a business, you must register with the National Credit Regulator and carry an NCRCP number. If you provide capital to an organisation that is already registered, and that organisation grants the credit, the obligation is theirs and not yours. Most private lenders in South Africa are in the second position. The practical work for them is not becoming registered — it is checking that the operator they deal with already is.
01 — The test
Which side of the line are you on?
Ask one question of any arrangement: who is the credit provider in the agreement with the borrower? Whoever that is carries the registration obligation. Everything else is detail.
If the answer is “me” — you are lending directly to individuals, at interest, as a repeated commercial activity — then the National Credit Act is speaking to you and registration is not optional.
If the answer is an organisation you are supplying capital to, the obligation is theirs. You are not party to the credit agreement with the borrower; they are.
One question, not five
Whose name is on the credit agreement with the borrower? That is the party the Act binds.
It is worth being blunt about why this matters so much in practice. Registration is not a form. A registered credit provider carries affordability-assessment duties, prescribed disclosure, statutory caps on what it may charge, record-keeping obligations and the Regulator’s supervision. Nobody takes that on to place a single sum of capital, and nobody should have to.
02 — The obligation
What being a registered credit provider actually involves
Registration with the National Credit Regulator is an application, an annual fee, and a continuing compliance regime. The number issued — the NCRCP — is public, and so is the register.
Who must register
The party granting credit to consumers
Regulator
National Credit Regulator
The number
NCRCP — public and checkable
Where
ncr.org.za
The duties that come with it are the substance. An affordability assessment before credit is granted. Prescribed pre-agreement disclosure. Interest and fees within the statutory ceilings. Records kept and returns filed. Conduct standards enforceable by the Regulator.
That burden is the reason the structure described on this page exists at all. It is efficient for one properly resourced entity to carry a compliance regime and for capital to reach borrowers through it — the same reason you do not personally underwrite the loans your bank makes with your deposit.
03 — The exclusions
Arrangements the Act does not reach
The National Credit Act is consumer-protection legislation. It aims at the individual borrower, and it steps back where the borrower is not one.
- Large juristic persons. A credit agreement with a company, close corporation, partnership or trust whose asset value or annual turnover is at or above the threshold falls outside the Act.
- Parties not at arm’s length. Arrangements between connected parties are treated differently from commercial lending to strangers.
- Certain agreement types are excluded or partially excluded by the Act itself.
These exclusions are genuine, and they are also the place where confident wrong answers get given. Whether a particular arrangement falls inside or outside the Act is a legal question about that arrangement, not a general rule you can apply from a web page. If your plan depends on an exclusion, get it checked by an attorney.
04 — The practical route
The route most private lenders actually take
Capital is placed with an organisation that already holds the registration. That organisation lends to its borrower class, administers the agreements, and carries the compliance. The capital earns a return as the borrowers repay.
Nothing about this requires the person supplying the capital to register anything, hold any licence, or file anything with the Regulator. What it does require is diligence on the operator — because their registration is now load-bearing for you.
| You | The registered provider | |
|---|---|---|
| Provides capital | Yes | — |
| Grants credit to borrowers | No | Yes |
| Holds an NCRCP number | No | Yes |
| Carries NCA compliance | No | Yes |
| Earns a return as loans repay | Yes | — |
05 — Where ProLend fits
Where ProLend fits
ProLend distributes private lending in South Africa. It is not a lender and it does not grant credit. The lending is administered by BC Funding Solutions (Pty) Ltd, registered credit provider NCRCP 11132 and FSP 55147.
So the answer for someone placing capital through ProLend is the second one on this page: you do not register, because you are not the party granting credit. BC Funding Solutions is, and their number is checkable at ncr.org.za without asking anybody’s permission.
ProLend’s consultants explain the structure and introduce clients. They are not advisers and do not make recommendations.